This Personal Data Protection explains Snootme's policies and procedures for collecting, using, and disclosing information through www.snootme.com (“Site”).
It covers websites, features, applications or online services owned or controlled by Snootme that link to this Personal Data Protection Policy (collectively with the Site, the “Service”).
It also includes any information Snootme might collect offline in connection with the Service.
This Personal Data Protection Policy describes your choices for using, accessing, updating, and correcting your personal information. It incorporates by reference the Snootme Personal Data Protection Policy.
Snootme (the “Platform”) is committed to protecting and respecting your privacy. This Personal Data Protection Policy explains how we collect, use, disclose, and safeguard your personal data in compliance with the General Data Protection Regulation (GDPR).
Note that we combine the information we collect from you through the Site, the Service, and offline, in order to be fully RGPD compliant.
If you have an unresolved privacy or data use concern that we have not addressed to your satisfaction, please contact us at legal@snootme.com.
Certain features or services mentioned in this Personal Data Protection Policy may not always be available on the Service.
Please also review our Terms of Use, which governs your use of the Service and is accessible at https://www.snootme.com.
We’ve provided here and there short summaries in our legal documents (in italics throughout) to help you to better understand them.
While these summaries explain some concepts simply and clearly, we encourage you to read the entire article when applicable to your case.
The data controller responsible for your personal data is:
- Luminaries Web-RTV srl
- Contact Information : legal@snootme.com
Information You Provide to Us
When you use the Service, you may provide us with Formal and Unformal information about yourself.
Formal information may include your name, contact details, financial information for making or receiving payments through the Snootme platform, or information to help us complete tax forms.
What we refer to as 'Formal information' is distinct from the ‘Unformal information’ you provide in your Project Form, photographs or review session, which is in no way consolidated or linked to formal data that could identify you.
We also collect information related to your use of the Service and aggregate it with data from other users to improve our Services for you.
Types of Formal Information Collected
Types of Unformal Information Collected
These recordings are exclusively used to:
This Unformal information are in no way consolidated or linked to formal data in order to identify Unformal information author who has chosen to remain anonymous.
Non-Identifying Information/Usernames: This includes zip codes, demographic data, information about your use of the Service, browser type, usage statitstics, and general project-related data. We may convert Personal Information into Non-Identifying Information using a hash function, creating "Hashed Information" that does not identify you directly but may connect your activity and interests.
Combination of Formal and Non-Identifying Information: When non-identifying information is combined with Personal Information, it can identify an individual. For example, combining a birthdate with a first name. Snootme will treat combined information as Personal Information.
You do not have a statutory obligation to provide us with any information, but you may have a contractual obligation to do so e.g. information about payment, and if we do not receive certain information from you, then we will not be able to provide our Service to you.
If you have any questions regarding whether provision of information is mandatory and the consequences for withholding such information, please contact us at legal@snootme.com.
Information Received from Third Parties
We may also receive information about you from third parties.
For instance, we may enhance the information we gather with data from external sources, or third parties may provide information as part of a co-marketing arrangement or upon your request (for example, if you choose to sign in using a third-party service such as Facebook or Instagram).
When we combine information received from others with information collected through our Service, we will treat the combined information as outlined in this Personal Data Protection Policy, considering it as Personal Information
Information Collected Automatically
Like other online companies, we collect technical information when you use our Services.
We use these technologies to analyze how people use the Service, enhance our Site's functionality, save your log-in information for future sessions, and reduce the delivery of advertisements that may not interest you.
We and our third-party service providers, including analytics and content providers, automatically gather certain information whenever you access or interact with the Service.
This may include your browser and operating system, the URL or advertisement that referred you to our Service, search terms used to find us, areas of the Service visited, links clicked, pages viewed and duration, and other statistics like content response times and download errors. We may combine this data with other information collected about you to improve the services we provide, and to enhance marketing, analytics, and site functionality.
Additionally, we collect your Internet Protocol (“IP”) address or other unique device identifier (“Device Identifier”) for any device (computer, mobile phone, tablet, etc.) accessing the Service. A Device Identifier is a number assigned to your device, and our servers use it to identify your device. Some mobile service providers may also provide us or our third-party service providers with location information about the device used to access the Service.
Snootme and its partners use cookies or similar technologies to analyze trends, manage the website, track user movements across the website, desktop app, and mobile app, and collect demographic information about our user base as a whole.
Cookies: We and our partners use “cookies” to collect information, like many websites. Cookies are small data files transferred to your computer’s hard drive. We use persistent cookies to store registration IDs and login passwords, and session ID cookies for features and usage tracking. You can manage cookies in your browser settings, but disabling them may limit access to some features. For details, see our Cookie Policy at https://www.snootme.com.
Web Beacons and Tracking Tags: We and partners may use “web beacons” and “tracking tags” to evaluate content effectiveness and deliver targeted ads. Web beacons are small, invisible graphics embedded in web pages or emails to track activities like visitor counts, navigation, email opens, and content views.
Embedded Scripts: We may employ “Embedded Scripts” to track interactions like link clicks. This code is temporarily downloaded to your device and deactivated after use.
Other Technologies: Additional technologies like tags are used for security and fraud detection, sometimes by third parties on our behalf.
Snootme does not respond to Do-Not-Track signals.
Please note that your browser setting may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit.
There is no consensus among industry participants as to what “Do Not Track” means in this context.
Like many websites and online services, Snootme does not alter its practices when it receives a “Do Not Track” signal from a visitor’s browser.
To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com .
To comply with the GDPR, Snootme publishes this Data Processing Agreement (DPA) on its platform.
This governs the relationship between the Customer (acting as a data controller or processor) and Snootme (acting as a data processor or subprocessor).
If Snootme processes any EU personal data for you as a controller under the GDPR, the DPA applies unless otherwise agreed in writing.
Diaries: We collect information about a Reviewer’s diary. When a Reviewer schedules a meeting on the platform, we access this information.
User Profiles: As a user you create profile featuring information about yourself, including Personal Information, photographs, project information, …. This Profile is shared only with your Reviewer for Review sessions purpose. Users can edit their Profile information and choose what to share. To request information or data removal, please contact us at legal@snootme.com.
Identity Verification: We place a premium on trust in our Service, so we take steps to verify Reviewer’s identity. Before a Reviewer can complete registration on the Service, or at any time thereafter, we request identity verification and update.
As Snootme Reviewers, they are obligated by a non-disclosure undertaking towards Users and are also bound by other agreements and liabilities towards the Snootme platform.
We make every effort to ensure that the user can trust that the Reviewer appearing in the video conference is indeed who they claim to be.
However, in preventing fraud, it is also the User's responsibility to conduct prior checks online to be able to detect identity fraud during the meeting. Snootme cannot be held responsible for Reviewers' identity theft or misrepresentation towards Users.
Visio conferencing: Reviewers and Users communicate with each other through the Service, via the online video conference. Without prejudice to the rights arising from non-disclosure undertaking aimed at protecting the User, the User is solely responsible for the information they choose to disclose to the Reviewer on this occasion and Snootme cannot be held responsible for the use that the Reviewer may make of this information.
Community Forums: We may offer public forums or blogs. If you participate, your comments and questions will be publicly displayed.
The Service may provide you the opportunity to participate and post content publicly in forums, on blogs, through interactive features on Snootme and through other communication functionality (“Community Forums”). You may choose, through such features or otherwise, to submit or post questions, comments, or other content (collectively, “User Forum Content”). Please note that certain information, such as your name and Profile may be publicly displayed on the Service along with your User Forum Content. Please note that your use of Community Forums is subject to the Snootme Terms of Use.
Note that anything you post to a Community Forum is public — others will have access to your User Forum Content and may use it or share it with third parties. If you choose to voluntarily disclose Personal Information in your User Forum Content or use Community Forums to link to your Profile, that information will be considered public information and the protections of this Personal Data Protection Policy will not apply .
To request removal of your personal information from our blog or community forum, contact us at legal@snootme.com . In some cases, we may not be able technically to remove your Personal Information, in which case we will let you know if we are unable to do so and why.
Testimonials: We display personal testimonials of satisfied customers on our Platform, in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at legal@snootme.com.
Work Listings Through the Platform: If you agree to post a picture on our platform because it has been chosen by a Reviewer, this content will be viewable publicly.
Feedback: We collect public and private feedback from Snootme Users about their experience with their Reviewer or about our Service. Please note that any public feedback that you provide via the Platform about your experience is publicly viewable via the Service. On rare occasions, we may remove feedback pursuant to the relevant provisions of our Terms of Use. Any private feedback that you provide via the Platform about your experience with Reviewers or about our Service will not be publicly viewable via the Service.
We also collect feedback from Users about our Service. We use this information to respond to your inquiries, improve the Service and how our Platform functions, and develop new products and features.
General purpose:
We also process personal data for the following purposes:
1. Service Provision: To provide, manage, and personalize our services.
2. Communication: To communicate with users regarding their accounts, transactions, and service updates.
3. User Experience: To improve user experience and enhance platform functionality.
4. Security: To protect against fraud, abuse, and unauthorized access.
5. Legal Compliance: To comply with legal obligations and protect our legal rights.
We rely on the following legal grounds to process personal data:
1. Contractual Necessity: Processing necessary for the performance of service provided to the user.
2. Consent: Processing based on user consent for specific purposes.
3. Legitimate Interests: Processing based on our legitimate interests in providing and improving our services.
4. Legal Obligation: Processing necessary to comply with legal obligations.
We collect and use information through Snootme to provide, improve, and secure our services, process requests, prevent fraud, send you relevant information and advertisements, comply with legal requirements, and with your consent.
We do not share your information except for essential service functions and promotions, such as sending newsletters via email management services. We use your information to enhance our service delivery, communicate with you, personalize content and offers, manage business relationships, enforce legal obligations, and pursue legitimate interests like improving our services and ensuring security.
This use of your Personal Information aligns with our contractual commitments, legitimate interests, and legal obligations.
We use information collected through the Service to provide and improve the Service, process your requests, prevent fraud, provide you with information and advertising that may interest you, comply with the law, and as otherwise permitted with your consent.
We do not share Formal or Unformal information to any third-party, for no other reasons than the proper functioning of the Service and its promotion e.g. sending newsletters through email management service.
WE USE INFORMATION WE COLLECT:
We use your Personal Information for the purposes described above:
Unless you request that we delete certain information, we retain Unformal information you submit for the Service purpose (Project form, Photographs, video recording, …) 12 months after your review session. Other Formal information we collect for legal and tax purpose are retained for at most 7 years.
Project-related information you shared i.e. project details and photos, are only disclosed to your selected Reviewer for the Service purpose only and to legal authorities for legal reasons (e.g., investigations). Formal personal information is shared to third parties for payment purpose only, legal compliance, mergers, or with your prior consent. No project-related information or identifying data are shared with third party for any other reasons than the Service supplying User has paid for.
Project related information and photographs you upload for the Service purpose will never be disclosed by Us, except for legal investigation or upon legal authorities requests e.g. violation of intellectual property rights or to the right to privacy of third party, child pornography….
We share information about the Project (project form and photographs) to your Reviewer through the platform.
We may share information about you to provide the Services, for legal and investigative purposes, in connection with sweepstakes and promotions, or if we are part of a merger or acquisition.
We may also share non-identifying information with third parties. You have choices as to whether we share your personal information with third parties for their own marketing purposes.
We may share aggregated Non-Identifying Information and we may otherwise disclose Non-Identifying Information (including, without limitation, Hashed Information) to third parties. We do not share your Personal Information with third parties for those third parties’ marketing purposes unless we first provide you with the opportunity to opt-in to or opt-out of such sharing.
We may also share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information, with your consent, as otherwise described in this Personal Data Protection Policy, or in the following circumstances:
Your full name as mentioned through payment details will be communicated to your Reviewer only when a dispute arises between you and him, and if it facilitates the resolution of a claim or dispute.
The Reviewer receiving your information is not allowed to use it for purposes unrelated to the transaction, such as to contact you for marketing purposes, unless you have expressly consented to it.
to you, or support and supplement the Services we provide. We may sell, transfer, or otherwise share some or all of our assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets (including, in each case, as part of the due-diligence process with any potential acquiring entity) or in the event of bankruptcy.
This information to which these third parties would have access, never includes your project-related information (Project Form, video or your photographs uploaded on the photo gallery of your personal space on the Platform).
We may work with advertising agencies and providers who use technology to help us understand how people use our Site. These partners may use technologies to serve you advertisements that may interest you. You can choose to opt out of receiving interest-based advertising.
Snootme works with (or may in the future work with) network advertisers, ad agencies, analytics service providers and other vendors to provide us with information regarding traffic on the Service, including pages viewed and the actions taken when visiting the Service; to serve our advertisements on other websites, within mobile apps and elsewhere online; and to provide us with information regarding the use of the Service and the effectiveness of our advertisements.
Our service providers may collect certain information about your visits to and activity on the Service as well as other websites or services, they may set and access their own tracking technologies on your device (including cookies and web beacons ), and may use that information to show you targeted advertisements. Some of these parties may collect Personal Information when you visit the Service or other online websites and services. We may also share certain Non-Identifying Information with these parties, including Hashed Information, in connection with the services they provide to us.
According to GDPR EU-law, you have rights regarding your personal information:
According to applicable law, you may have certain choices and rights associated with your personal information.
Communication Preferences.
Data Subject Rights.
In accordance with applicable law, you may have the right to:
We will use commercially reasonable efforts to honor your requests for deletion; however, certain information will actively persist on the Service even if you close your account, including information in your Work Diaries and messages you posted to the Service.
In addition, the rights described above may be limited, for example, if fulfilling your request would reveal personal information about another person, or if you ask us to delete information we are required by law to keep or have compelling legitimate interests in keeping (such as for fraud prevention purposes).
Your Personal Information may remain in our archives and information you update or delete, or information within a closed account, may persist internally for our administrative purposes, to the extent permitted by law. In addition, we typically will not remove information you posted publicly through or on the Service. Bear in mind that neither you nor Snootme can delete all copies of information that has been previously shared with others on the Service.
To exercise your rights, please contact us at legal@snootme.com. We will respond to your request in accordance with GDPR timelines.
Data Storage and Processing Facilities.
Snootme may store and process the relevant User Data anywhere Snootme or its Sub processors maintain facilities.
Transfers of Data Out of the EEA, UK, and Switzerland.
User authorizes Snootme and its Sub processors to make international transfers of User Personal Data in accordance with applicable law and this Policy.
We take a number of steps to protect your data, but no security is guaranteed.
Snootme takes commercially reasonable steps to help protect and secure the information it collects and stores about Snootme Users. All access to the Site is encrypted using industry-standard transport layer security technology (“TLS”).
When you enter sensitive information (such as tax identification number), we encrypt the transmission of that information using secure socket layer technology (“SSL”).
We also use HTTP strict transport security to add an additional layer of protection for our Snootme Users.
But remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Thus, while we strive to protect your Personal Information, Snootme cannot ensure and does not warrant the security of any information you transmit to us.
If Snootme becomes aware of a Data Incident, Snootme will: (a) notify User of the Data Incident promptly and without undue delay after becoming aware of the Data Incident; and (b) promptly take reasonable steps to minimize harm and secure User Data.
The profile you create on our Site will not be publicly accessible. This means that except your Reviewer who get a limited access to your (nick)name, Project Form and photography uploaded in the related project gallery, it will not be visible to the entire Internet, including clients, visitors, and search engines.
User agrees that, without prejudice to Snootme’s obligations under sections Data Security and Data Retention:
a. User is solely responsible for its use of the Service, including:
b. Snootme has no obligation to protect User Data that User elects to store or transfer outside of the Service
Our Service may contain links to other websites.
If you choose to click on a third-party link, you will be directed to that third party’s website.
The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices.
We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit Personal Information from you.
We encourage you to read the Personal Data Protection policies or statements of the other websites you visit.
Phishing websites imitate legitimate websites in order to obtain personal or financial information.
Identity theft and the practice currently known as “phishing” are of great concern to Snootme.
For more information about phishing, visit the website of the Federal Trade Commission at http://www.consumer.ftc.gov/articles/0003-phishing .
In addition, if you believe you have received an email or had a similar interaction with a third party pretending to be Snootme, please report it at legal@snootme.com.
We may change this Personal Data Protection Policy.
Snootme may update this Personal Data Protection Policy at any time and any changes will be effective upon posting.
In the event that there are substantial changes to the way we treat your Personal Information, we will display a notice through the Services prior to the change becoming effective.
We may also notify you by email, in our discretion. However, we will use your Personal Information in a manner consistent with the Personal Data Protection Policy in effect at the time you submitted the information, unless you consent to the new or revised policy.
If you have any questions about this Personal Data Protection Policy or our data practices, please contact us at legal@snootme.com.